Alexander v. WMATA, No. 15-7039 (D.C. Cir. 2016)
Annotate this CasePlaintiff filed suit against the Authority, alleging disability discrimination under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq. The district court granted summary judgment to the Authority. The court concluded that the district court erred by focusing on only the first definition of "disability" and failed to consider whether plaintiff met either the record-of-impairment or regarded-as-impaired definitions of disability. Compounding the error, the district court also applied an outmoded statutory standard, overlooking material changes to the governing law worked by the 2008 Amendments. Given the legal standard prescribed by the 2008 Amendments, the court held that petitioner came forward with sufficient evidence to permit a reasonable jury to find that his alcoholism substantially limited major life activities compared to most people in the general population. Furthermore, petitioner's complaint was timely filed under both the three-year and one-year limitations periods provided by District law. Accordingly, the court affirmed the judgment.
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